Experience With DOL Audit of Converted Cash Balance Plan?

[Guest DJK]

We have a client that has received a DOL audit notice for its defined benefit plan. The client converted the plan from a traditional defined benefit plan to a cash balance plan last year. Does anyone have any experience with DOL audits of converted cash balance plans, and ideas as to what type of unique cash balance plan issues the DOL is likely to focus on in such audits?

FYI - We're aware of the guidance that the DOL has issued on this issue (e.g., (1) the preamble to the final summary plan description regulaion, issued on 11/21/2000, that addresses issues concerning SPDs and cash balance plans and (2) the PWBA's Q&As re: cash balance plans from November 1999).

Thanks for any insights!!